Ronald Lee Snyder - Page 15

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          petition in this case, petitioner made statements and requests              
          and advanced contentions and arguments that the Court has found             
          to be frivolous and/or groundless.  In that petition and the                
          supplement thereto, petitioner persists in advancing such frivo-            
          lous and/or groundless statements, requests, contentions, and               
          arguments.  Consequently, even though we held in Keene v. Commis-           
          sioner, 121 T.C. 8, 19 (2003), that section 7521(a)(1) requires             
          the Appeals Office to allow a taxpayer to make an audio recording           
          of an Appeals Office hearing held pursuant to section 6330(b), we           
          conclude that (1) it is not necessary and will not be productive            
          to remand this case to the Appeals Office for another hearing               
          under sections 6320(b) and 6330(b) in order to allow petitioner             
          to make such an audio recording, see Lunsford v. Commissioner,              
          117 T.C. 183, 189 (2001), and (2) it is not necessary or appro-             
          priate to reject respondent’s determinations to proceed with the            
          collection action as determined in the notice of determination              
          and in the decision letter with respect to petitioner’s unpaid              
          liability for 1994, petitioner’s unpaid liability for 1996, and             
          petitioner’s respective unpaid liabilities for 1998 and 1999, see           
          id.9                                                                        
               Based upon our examination of the entire record before us,             


               8(...continued)                                                        
          to respondent his request to make an audio recording of his                 
          hearing with the Appeals Office in advance of that hearing.                 
               9See Kemper v. Commissioner, T.C. Memo. 2003-195.                      




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